IMF国际货币组织全球-Review-Of-The-Fund-s-Policy-On-Multiple-Currency-Practices_Initial-Considerations_130页_2mb
报告摘要
IMF Policy Paper Summary: Review of the Fund's Policy on Multiple Currency Practices
Core Content
The International Monetary Fund (IMF) conducted a review of its policy on multiple currency practices (MCPs) in 2019, as requested by Executive Directors. The policy, which has not been comprehensively reviewed since 1981, is a cornerstone of the Fund's legal and policy framework for exchange rates. The review aimed to modernize the policy to better align with current market realities and improve its effectiveness.
The current MCP policy prohibits members from introducing and maintaining multiple exchange rates unless under transitional arrangements or temporarily approved by the Executive Board. The policy applies to both spot and non-spot transactions, with a permissible spread of up to 2% for spot transactions. However, the policy has become outdated due to significant changes in foreign exchange (FX) markets, including greater experience with flexible exchange rates, improved data availability, and the development of hedging products.
Main Points
- Definition of MCP: An MCP arises when official action leads to exchange rate spreads that exceed commercially reasonable levels. It is not about maintaining multiple currencies, but rather multiple exchange rates.
- Scope of Official Action: The policy should focus on actions that segment FX markets, excluding certain practices such as FX auctions that follow best practices, illegal parallel markets, and lagged official exchange rates.
- Revising the Two-Percent Rule: The fixed 2% rule for spot transactions will be replaced with a country-specific market-based norm, including a tolerance margin, to reflect actual market conditions.
- Non-Spot Transactions: The permissible spread for non-spot transactions will be assessed relative to similar transactions, with a focus on commercial costs and risks.
- Broken Cross-Rates: These will no longer be considered MCPs, as they are no longer common.
- Approval Policies: Approval for MCPs will be limited to balance of payments (BOP) reasons, and non-BOP MCPs will no longer be approved.
- Capital Transactions: The link between MCPs and capital flow management (CFM) measures is being reconsidered, with the possibility of assessing such MCPs under the Institutional View (IV).
- Remedial Framework: The paper discusses the potential for a formal remedial framework to address unapproved MCPs, though this requires further analysis.
- Transitional Arrangements: The Fund will provide transitional arrangements to allow member countries to adjust to the new policy.
Key Reforms Proposed
- Clarify "Official Action": Focus on actions that segment FX markets, excluding non-distortionary practices.
- Eliminate Potentiality: MCPs will only be identified if actual spreads exceed permissible thresholds.
- Update Permissible Spreads: Replace the fixed 2% rule with a market-based norm for spot transactions.
- Align Approval Policies: MCPs for non-BOP reasons will no longer be approved.
- Reconsider Capital Transactions: MCPs on capital transactions may be included in the policy framework, assessed under the IV if they constitute CFMs.
- Consider Remedial Framework: A framework for addressing unapproved MCPs could be introduced, but its merits must be carefully evaluated.
Operational Considerations
- The current policy has become increasingly complex and difficult to apply, affecting policy implementation and member engagement.
- The review includes a detailed analysis of the economic context, experiences, and methodology for assessing MCPs.
- The Executive Board generally supported the reform proposals, emphasizing the need for rules that reflect market realities and are consistent across the Fund's membership.
- A formal proposal for reform, including draft decisions, will be presented to the Board following further consultation and analysis.
Next Steps
- The Executive Board will review the paper in an informal staff briefing and then in a formal meeting.
- Based on this review, a formal proposal for reform will be prepared, followed by a guidance note for staff to implement the new policy.
- Periodic reviews of the new MCP policy and its implementation are expected in the future.
Summary Table of Key Challenges and Proposed Reforms
| Challenge | Current Treatment | Proposed Reform |
|---|---|---|
| "Official action" is applied too broadly | Captures spreads even if there is no "market segmentation" | These practices will no longer be considered official action: (i) FX auctions that conform to best practice, (ii) illegal parallel markets, (iii) (1-day) lagged official exchange rates |
| "Two-percent" rule no longer reflects market realities | Spread of more than 2% for spot transactions gives rise to MCP | Spread exceeding the higher of the country-specific market-based norm or a tolerance margin will give rise to MCP |
| Treatment of non-spot FX transactions is unclear | Spread relative to spot rates exceeding normal commercial costs and risks | Spread relative to similar non-spot transactions exceeding the higher of the country-specific market-based norm or a tolerance margin will give rise to MCP |
| Broken cross-rates are no longer common | Broken cross-rates constitute MCPs | Broken cross-rates will no longer constitute MCPs |
| Approval policies for MCPs are misaligned with those for exchange restrictions | MCPs can be approved for both BOP and non-BOP reasons | MCPs will no longer be approved for non-BOP reasons |
| Link with capital transactions needs clarification | MCPs on capital transactions do not require approval | MCPs on capital transactions may be included in the policy, assessed under the IV if they constitute CFMs |
Conclusion
The review of the MCP policy highlights the need for modernization to reflect current FX market practices and ensure the policy remains relevant and effective. The proposed reforms aim to simplify the policy, align it with market realities, and enhance transparency and cooperation with member countries. The next steps involve formal discussions, the development of a reform proposal, and the issuance of a guidance note for staff.
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